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They also submit that servicemen resident In Quebec before going overseas were taxed under paragraph 250(1)(b) of the Act, that is, as persons deemed resident in Canada, and that the province of Quebec considered them not to be resident in the province and therefore exempt from provincial income tax. ...

Counsel for the Minister however contends that the $169,500 should be considered as a shareholder benefit or appropriation as opposed to earned income. ...

However, nothing in the documents signed this day shall be considered as causing any of the parties hereto to lose any right whatever against any other party in the said case; 3. ...

He stated, in a report filed, in referring to what he considered a comparable situation: “The market value of a property was declared at $100,000 in the Land Title Office. ...

The correspondence went on to say that they were considered prescribed shares because of the four benefits set forth in the Resume and it was on this basis that the determination was made that they were prescribed shares. ...

Rather than be construed as a secondary intention to “flip” the property, this conduct should be considered the act of a prudent person attempting to get out from under. ...

This, it was argued, is an issue which more properly should be considered by the Federal Court-Trial Division, since it involves a dispute as to whether the appellant or his employer owes the relevant amounts. ...

The Minister of National Revenue has considered the reasons set out in your objection and all the relevant facts. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

That doubt is intensified and becomes disbelief when the objective facts are considered. ...